Mirror Worlds, LLC v. Apple, Inc.

Filing 137

Joint MOTION for Extension of Time to File Parties to Comply with Patent Local Rule 4-3 by Apple, Inc., Mirror Worlds, LLC, Mirror Worlds Technologies, Inc.. (Attachments: #1 Text of Proposed Order)(Smith, Stefani)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 137

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. JOINT MOTION FOR AN EXTENSION OF TIME FOR THE PARTIES TO COMPLY WITH P.R. 4-3 Mirror Worlds, LLC ("Mirror Worlds"), Mirror Worlds Technologies, Inc. ("MWT"), and Apple Inc. ("Apple") (collectively, "the parties") hereby move to extend the deadline to comply with Patent Local Rule 4-3 until Friday, November 13, 2009. Good cause exists for the requested relief. The parties' present deadline to comply with Patent Local Rule 4-3 is Friday, October 30, 2009. The parties are still engaging in the meet and confer process to narrow the claim Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED

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construction disputes. Accordingly, the parties respectfully request the Court to extend the time to comply with Patent Local Rule 4-3 to Friday, November 13, 2009. This extension is not sought for the purpose of delay, but instead so that justice may be served. WHEREFORE, PREMISES CONSIDERED, the parties respectfully request the Court to grant their motion to permit the parties to submit their 4-3 statements as described above.

Dated: October 29, 2009 /s/ Richard An Otis Carroll Texas Bar No. 03895700 Lead Attorney Deborah Race Texas Bar No. 16448700 IRELAND, CARROLL & KELLY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 903-561-1600 (Telephone) 903-581-1071 (Facsimile) [e-mail] Of counsel: Joseph Diamante (Pro Hac Vice) Kenneth Stein (Pro Hac Vice) Richard An (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, NY 10038 212-806-5400 (Telephone) 212-806-6006 (Facsimile) [e-mail] [e-mail] [e-mail] Attorneys for MIRROR WORLDS, LLC and MIRROR WORLDS TECHNOLOGIES, INC.

Respectfully submitted, /s/ Stefani Smith Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 [phone] (Telephone) [phone] (Facsimile) [e-mail] Matthew Powers Lead Attorney Steven S. Cherensky Sonal N. Mehta (Pro Hac Vice) Stefani C. Smith (Pro Hac Vice) WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (Telephone) 650-802-3100 (Facsimile) [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for APPLE INC.

CERTIFICATE OF SERVICE This is to certify that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this day, October 29, 2009. /s/ Stefani Smith Stefani C. Smith